Welcome to Pathways, your quarterly newsletter!
The tides are turning in the environmental industry with the EPA’s first-ever PFAS national drinking water standard and CERCLA designations for PFOA and PFOS this year. In this issue we address the impacts of these new regulations and provide solutions.
On April 10, 2024 the U.S. Environmental Protection Agency (EPA) categorized a pair of widely used industrial chemicals, PFOS and PFOA, as hazardous substances under the country's Superfund program.
Fifteen days later the EPA announced its first drinking water standards to guard against PFAS pollution.
The Superfund designations will ensure that responsible parties "pay for the costs to clean up pollution threatening the health of communities," EPA Administrator Michael Regan said in a statement. The EPA has reported that it would prioritize enforcement against significant contributors to the release of PFAS, such as federal facilities and manufacturers.
Not everyone is jumping for joy with these two final rule makings.
The American Chemistry Council called the rule "severely flawed" and said the chemicals have not been produced in the United States in nearly a decade. The Superfund program "is an expensive, ineffective and unworkable means to achieve remediation for these chemicals," the group said in a statement.
Meanwhile Environmental groups praised the EPA's move. "These designations will give PFAS-contaminated sites the attention they deserve," Earth justice attorney Jonathan Kalmuss-Katz said in a statement.
If you’re concerned about possible PFAS soil or groundwater impacts on your business or property value:
Include PFAS in your site investigations. The analytical costs are greater than traditional sampling methods, however, the potential risks of not being fully informed of the extent of the contamination are substantial. And remember, PFAS moves quickly in groundwater, so the longer you wait, the larger the treatment area will be.
If you find regulated PFAS compounds, it’s time to discuss with your attorney or consultant what your next steps should be in terms of source identification, regulatory notifications and compliance, litigation risk mitigation, or what this might mean finalizing real estate transactions.
If you eventually find yourself having to remediate soil or groundwater, connect with Cascade for innovative in situ PFAS treatment technology alternatives to pump and treat.
One note of caution:
One common situation for PFAS contamination is fighting fires and fire training. These have been some of the largest releases by industry or government. While DOD has been very aggressive in gearing up to address PFAS, there have been thousands of car fires, tanker spills/fires, and gas station fires across the U.S. for many years. Most of these incidents have been managed with AFFF firefighting foam. If you own these properties or adjacent properties that have been impacted, it makes sense to proactively look for PFAS and take action against those responsible for the releases. In many cases, this would be local fire departments or fuel haulers. Fire departments may be tougher to get relief since regulators said they do not intend to sue fire departments that may have inadvertently polluted drinking water supplies by using PFAS-laden products.
Due to resilient nature of PFAS, traditional sampling methods are not suitable and don’t provide enough insight into the subsurface to meet the enforceable MCLs set by the EPA earlier this year. Treatment options such as high temperature thermal, and injection chemistries coupled with automated injection systems are on the top of the list as remediation technology options that provide problem-solving options associated with PFAS contamination.
As with any remediation project, especially for PFAS, site characterization is the first step to define the extent of PFAS contamination and the pathways it’s moving through groundwater. WaterlooAPS™ provides these capabilities to define flux and has been used on many state and federal PFAS sites across the country, as well as 1,4 dioxane and CCR metals. This aquifer profiling system is a complete mobile direct push subsurface data collection platform, combining high-quality discrete groundwater sampling capability with continuous, real-time hydrostratigraphic logging.
Utilizing this discrete sampling collection technology provides the managing consultant insights as to the vertical and lateral groundwater contamination levels in transmissive zones to quantify mass flux. Developing a valid Conceptual Site Model (CSM) is the single most important activity for ensuring that sound site management decisions and design are made for mitigating risk and complying with regulatory standards.
Want to learn more about WaterlooAPS? Get in touch with our HRSC experts to characterize your PFAS site.
While PFAS contamination is a growing concern, it's not the only persistent chemical threatening groundwater resources. This case study showcases our expertise in remediating a different type of groundwater contaminant. Read on to discover how in situ solidification and stabilization isolated a complex Tert-butanol (TBA) plume at an active shipping facility, ensuring a successful and cost-effective cleanup.
Over a four-month span our team tackled a challenging remediation project at a former paint manufacturing facility. The site suffered from ongoing groundwater contamination with site-specific Tert-butanol (TBA) resurfacing due to seasonal groundwater flow patterns. Traditional methods utilized in the early 2000s provided a temporary solution but didn’t solve the problem.
In Situ Stabilization was employed to solidify and stabilize the contaminated soil, preventing further TBA migration. However, the project encountered surprises: unexpected underground utilities and a backfill material that complicated excavation.
Download the full case study to see how Cascade's:
Quick thinking and problem-solving addressed the challenges.
Expertise in ISS ensured successful remediation.
Communication and collaboration kept the project on schedule and budget.
In what way can thermal remediation be applied in situ and ex situ to treat PFAS laden soil?
Heating the soil to approximately 400°C (750° F) has been demonstrated to be capable of removing all PFAS, including target compounds, precursors, products of incomplete degradation (PIDs), and even short-chained volatile fluorinated compounds (VFCs) such as C2F6 and CF4, which are both highly potent and long-lived greenhouse gases. Importantly, thermal remediation removes the PFAS compounds that are regulated today as well as those that may be regulated in the future, eliminating the specter of long-term liability.
TerraTherm has developed a patent-pending high temperature thermal remediation approach for treating PFAS contaminated source zones, where soil is heated to 400°C either in situ, or ex situ in specially engineered ex situ piles, using thermal conduction heating (TCH). TerraTherm has over 24 years of experience successfully applying high temperature thermal treatment with our proven TCH heating systems. Learn more about high temperature thermal as a solution to remediation PFAS in this webinar:
